According to the current position of tax authorities and administrative courts, the tax base for the solidarity levy can be reduced by tax losses from previous years. However, it should be noted that the deduction of tax losses is only possible within the same source of income. Solidarity Levy The solidarity levy has been…
What are financial transactions in the context of transfer pricing? Financial transactions encompass a wide range of intercompany activities, including loans, credit facilities, financial guarantees, bond issues, and other financial instruments. These are among the most common categories of related party transactions. To minimize the risk of income adjustments by tax authorities, the terms of…
An increasing number of companies are incorporating ESG (Environmental, Social, and Governance) factors into their business strategies. One of the key challenges in this process is tax risk, which can impact not only financial stability but also reputation and stakeholder relationships. A transparent and regulatory-compliant tax approach is no longer just a legal obligation –…
The tax on shifted income was intended to protect the Polish tax base from transfers income to tax havens. Initially, the regulations covered both domestic and cross-border payments, but after one year of being in force, the scope of the tax was limited to payments to non-residents only. This change has effectively become a time…
For years, financial, service, and distribution or production transactions have consistently been the most commonly reported in the TPR form. This is largely because they are easy to identify as subject to transfer pricing regulations. However, in a complex and rapidly evolving business environment, companies often engage in transactions that do not fit neatly into…
The Head of the National Revenue Administration [KAS] has refused to issue letter of practice regarding incentive programs (ref. DKP16.8082.4.2024 and DKP16.8082.7.2024). This decision raises questions about the tax security of such solutions and potential risks for companies implementing incentive schemes. Which incentive programs were challenged by the Head of KAS? In both cases, the…
Intangible services have long been a focus of tax authorities. It is therefore essential to understand the key risk areas associated with these service costs and to manage them proactively throughout the year—not just when preparing transfer pricing documentation. Confirmation of service performance (Benefit Test) When it comes to intangible services, taxpayers must be able…
Companies are increasingly investing in sustainable development. Green innovations not only help protect the environment but also bring tangible business benefits. One of the tools supporting companies in this transformation is the Research and Development (R&D) tax relief, which allows for additional deductions of specific expenses from the tax base. What is the R&D tax…
The approaching deadline for PIT settlements for 2024 poses a serious challenge for many taxpayers regarding how to correctly settle their income, especially foreign income when it comes from investments through foreign banks. This topic becomes particularly important for people who have investments in foreign banks (e.g. Switzerland, Germany, Austria, France, USA) and invest through…
The list of countries that have obtained “qualified” status for GloBE purposes is now known. The Ministry of Finance published an announcement on February 7, 2025, regarding the list of non-Polish jurisdictions that have implemented a qualified income inclusion rule or a qualified domestic minimum top-up tax or meet the requirements for safe harbors for…